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MDEP/RCRA Quality Assurance Plan Revision 6 Date: November 21, 2012 Page 0 of 19

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Page 0 of 19 Page 1 of 19 TABLE OF CONTENTS Title Page 1.0 Introduction Project Description QAP Implementation Quality Assurance Statement MDEP/RCRA Program Organization Organizational
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Page 0 of 19 Page 1 of 19 TABLE OF CONTENTS Title Page 1.0 Introduction Project Description QAP Implementation Quality Assurance Statement MDEP/RCRA Program Organization Organizational Hierarchy Personnel Responsible for QAP Implementation Assessment Laboratory Services Evaluation Internal Assessment External Evaluation Yearly QAP Reviews Data Quality Objectives Goal of the Site Assessment Data Use Data Quality Necessary for Project Procedural Requirements for Meeting QAP Sampling and Analysis Plan [SAP] Site Specific QAPP Implementation of SAP and Generation of Sampling Event Trip Reports [SETR] Equipment and Supplies Laboratory Services Standard Operating Procedures Data Quality Assessment Precision Accuracy Representativeness Completeness Comparability Sensitivity Document Control Corrective Action Implementation Schedule Distribution List List of Acronyms 19 Page 2 of 19 LIST OF APPENDICES Appendix A B C D E F Title Organizational Hierarchy of MDEP/RCRA MDEP/RCRA Standard Operating Procedure Manual And List of Available Equipment Maine Comprehensive and Limited Laboratory Certification Rules, April 2010 QAP Log Sheet Maine Certified Laboratories Crosswalk Between USEPA Document QA/R-5, EPA Requirements for Quality Assurance Project Plans for Environmental Data Operations and MDEP/RCRA QAP Page 3 of INTRODUCTION 1.1 PROJECT DESCRIPTION Under the Federal Resource Conservation and Recovery Act (RCRA) as amended, cooperative enforcement, corrective actions, closures and inspection agreements have been developed between the U.S. Environmental Protection Agency (EPA) and the Maine Department of Environmental Protection (MDEP). The MDEP is the state lead agency for RCRA regulatory programs and is authorized under the Maine Hazardous Waste Management Rules, as amended, to conduct RCRA enforcement, compliance, inspection, corrective action, closures and licensing programs. Examples of activities within these programs include the inspection of hazardous waste generators, complaint investigations for hazardous waste dumping (illegal disposal) and licensing of proposed hazardous waste storage and disposal facilities. Many of these activities include the sampling and analysis of various media to verify possible violations for enforcement purposes or to establish site conditions during the operation or closure of regulated facilities. Monitoring programs for groundwater protection are established by the MDEP at licensed RCRA facilities, and at facilities undergoing corrective actions for the purpose of site characterization and remediation. Samples may be taken during enforcement actions in an attempt to verify and or locate illegal disposal areas or to verify a complaint of illegal operations. The results of the analysis of such samples might be used as evidence if legal proceedings were to ensue. To support the activities of the RCRA program such as those mentioned above, and others, media and waste samples are submitted to a Maine certified laboratory. The MDEP designates field personnel (e.g. inspectors, environmental specialists, oil and hazardous materials specialists) who are responsible for collecting such samples and/or documenting field collection activities. Field personnel are responsible for maintaining the chain of custody by following appropriate procedures, until the samples are relinquished to appropriate laboratory personnel. The laboratory is responsible for maintaining verifiable custody and for analyzing the samples using analytical methods as requested by field personnel, following appropriate quality assurance protocols, and for transmitting analytical results and associated quality assurance/quality control data to the appropriate person(s). Page 4 of QAP Implementation The United States Environmental Protection Agency (EPA) requires that all environmental monitoring and measurement efforts mandated or supported by U.S. EPA participate in a centrally managed Quality Assurance Plan (QAP). Any party generating data under this program has the responsibility to implement nominal procedures to assure that the precision, accuracy, completeness, and representativeness of its data are known and documented. As stated in USEPA Executive order Policy and Program Requirements to Implement the Mandatory Quality Assurance (QA) Plan, the primary goal of the QAP is to ensure that all environmentally related measurements performed or supported by USEPA produce data of known quality. The quality of the data is known when all components associated with its derivation are thoroughly documented, with such documentation being verifiable and defensible. All Quality Assurance/Quality Control (QA/QC) procedures must be in accordance with applicable professional technical standards, USEPA requirements, government regulations and guidelines, and specific project goals and requirements. This document serves as the Maine Department of Environmental Protection Division of Oil and Hazardous Waste Facility Regulation (MDEP/RCRA) QAP. This document will describe, or reference attached documents that describe: The MDEP/RCRA functional statement and organization; Personnel responsible for assuring the standards set in the QAP are met; Quality standards goals; The basic flow of project activities, including preparation of sampling plans, implementation, report preparation, and document control; Equipment available to MDEP/RCRA staff and Standard Operating Procedures for conducting field work; and MDEP/RCRA procedures for obtaining analytical support. 2.0 QUALITY ASSURANCE STATEMENT It is the goal of the MDEP/RCRA to implement a Quality Assurance Program (QAP) for all environmental activities that generate data. The QAP is a management tool that will help guarantee that data is of sufficient known quality to withstand scientific and legal challenge relative to the use for which the data is obtained. Page 5 of MDEP/RCRA ORGANIZATION 3.1 Organizational Hierarchy The MDEP/RCRA organizational chart can be found in Appendix A. 3.2 Personnel Responsible for QAP Implementation Maine s Quality Management Plan (Revision 3, August 30, 2006) 1.4 reads, in part, Commitment to and responsibility for the quality objectives and operations detailed in any QAPP begins with the commissioner and continues through all levels of management and staff. As such, division and program-level managers bear primary responsibility for ensuring that the QA standards specified in this QAP are met. Program Manager Name: Scott Whittier Title: Director, Division of Oil and Hazardous Waste Facilities Regulation, Licensing and Enforcement Phone: (207) Responsibilities: The Director is responsible for the administration of division program assignments, administration of budget, supervision of division personnel and overall programs and ensuring compliance with the MDEP quality assurance program. Department Quality Assurance Officer Name: Andrew Johnson Title: Laboratory & Quality Assurance Coordinator, MDEP, Bureau of Air Quality Phone: (207) Responsibilities: Communicates all QAP updates to EPA, and communicates QMP and EPA requirements to MDEP/ RCRA Program personnel responsible for QAP implementation. Page 6 of 19 Project Quality Assurance Chemist Name: Kelly Perkins Title: Chemist III, MDEP, Bureau of Remediation and Waste Management, Division of Technical Services Phone: (207) Responsibilities: Review QAP annually, and send review report to Program Manager and Department QA Officer; send all approved QAP Updates to Program personnel responsible for QAP implementation; review Quality Assurance Project Plans for RCRA program contracts where appropriate; and provide technical guidance to project staff as requested. Quality Assurance Team: Quality assurance is the responsibility of supervisory and technical staff whose names, titles and phone numbers follow: Name Title Phone Number Stacy Ladner RCRA Licensing Unit Manager (207) Mike Hudson RCRA Enforcement Unit Manager (207) Bruce Hunter TS EHG Unit Manager (207) Fred Lavallee TS Engineering Unit Manager (207) Responsibilities: Perform or designate performance of periodic observation of sampling and sample handling techniques for conformity with MDEP/ RCRA Program guidance documents; provide guidance to Project Manager and project staff as requested. 4.0 ASSESSMENT Periodic assessments will take place in the following ways: 4.1 Performance Evaluation The laboratory will conduct standard performance studies as required by the appropriate certifying agency. MDEP accepts certification from USEPA, Maine Certification Program and the National Environmental Laboratory Accreditation Program [NELAP]. The laboratory shall maintain records of all performance evaluation studies. Problems identified in performance evaluation studies shall be immediately investigated and corrected. Page 7 of Internal Assessment Personnel responsible for performing field and laboratory activities are responsible for continually monitoring individual compliance with the QAP, SAP, and QAPP (if applicable). The Quality Assurance Team will periodically review procedures, results, and calculations to determine compliance with the QAP. The results of this internal assessment are discussed with appropriate staff and supervisors [as necessary] with suggestions and/or recommended requirements for a plan to correct observed deficiencies. 4.3 External Evaluation The field and laboratory activities may be reviewed by personnel external to the MDEP/RCRA, such as the Department QMP Audit Team. The results of any external assessment will be submitted to the RCRA Program manager with suggestions and requirements for a plan to correct observed deficiencies. 4.4 Yearly QAP Reviews The Project QA Chemist will conduct an annual review of the QAP, and a review report will be sent to Program Manager and Department QA Officer. 5.0 DATA QUALITY OBJECTIVES Data Quality Objectives (DQOs) are qualitative and quantitative statements that specify the quality of the data required to support decisions during site assessments. DQOs are dependent on the end uses of the data that is collected. Site specific DQOs will be established prior to collecting data and incorporated into the SAP or the QAPP. Three steps will be followed in developing DQOs. 1) Identify the goal of the site assessment. 2) Identify the use of the data. 3) Identify the data quality needed to meet the site assessment goal and data use. 5.1 Goal of the Site Assessment The project manager will identify the goal of the site assessment and state it in the SAP or QAPP. The goal will be based on a review of the available data and site specific conditions. Data will be evaluated based on such factors as: age, method, QA/QC, SOPs used by the collectors and laboratory, source of data (RP vs. State agency) and detection limits. The project manager will also identify site specific factors important to developing a site goal such as: likely contaminants, routes of Page 8 of 19 exposure, sources, nearby resources and targets that may be impacted by contamination from the site. 5.2 Data Use The data use(s) will be identified. Prior to collecting data the end use for that data should be identified. Data collected for the MDEP s RCRA site assessment may be used but not limited to any or all of the following: To determine the need for emergency action. To identify any waste materials and contaminants. To determine the quantity and levels of contamination. To identify impacted targets/receptors and natural resources. To document the need for further action or no further action. 5.3 Data Quality Necessary for Project The quality and quantity of data needed to meet the decisions made above will be identified. Factors that are considered in determining quality are: appropriate analytical levels (e.g. field screening, portable laboratory or fixed laboratory), contaminants of concern, levels of concern, required detection limit and critical samples. Additional data quality indicators that should be considered are precision, accuracy, representativeness, completeness and comparability (see Section 10 - Data Quality Assessment). The quantity of data needed will vary based on available usable data, data use and analytical methods used. The DQOs will be an intricate part of developing the SAP or QAPP. Analytical methods, compound analysis lists, method performance criteria, method detection limits, etc, for routine analytical analysis can be found in Appendix C - HETL Quality Assurance Manual, Section 3. In instances of non-routine analysis, these issues will be outlined in the project specific QAPP developed for the event. 6.0 PROCEDURAL REQUIREMENTS FOR MEETING QAP In order to assure the generation of quality data, several procedural steps must be followed prior to and following environmental data collection activities. These steps include: The generation of a Site specific QAPP (if determined necessary);-- The generation of a site-specific Sampling and Analysis Plan (if determined necessary); Page 9 of 19 Implementation of the Sampling and Analysis Plan (SAP); and generation of a Sampling Event Trip Report (SETR); Assessment of the Data to determine if the DQOs are met. 6.1 Sampling and Analysis Plan A Sampling and Analysis Plan (SAP) will be developed for sampling events requiring pre-project planning. The specific requirements for a MDEP/RCRA SAP can be found in SOP DR#014 in Appendix B. The SAP will define the proper procedures to be followed in the collection, preservation, identification and documentation of environmental samples and field data. The SAP shall outline the data quality objectives (DQOs) and protocols for data collection activities to ensure that the data generated by these activities are of a quality commensurate with their intended use. The SAP will include reference to the SOPs to be followed. Any planned deviation from the referenced SOP shall be described and an evaluation of the deviation s impact on the DQOs shall be included in the final report. The project manager will have overall responsibility for approving the site SAP with input from Technical Services personnel as necessary. SAPs will be reviewed for the elements described in SOP DR#014, approved by the Project Manager and kept with the project file. A SAP will not be required for incidental samples taken during inspection and licensing activities. Incidental samples may be taken for a variety of reasons related to checking sampling/ analysis activities of RCRA facilities and may include split sampling, emergency/rapid response sampling, routine sampling performed on a semi-annual or annual basis. Any such activities must be sampled according to appropriate sampling SOP, documented in field notes, and analyzed by approved methods at an appropriately certified laboratory. 6.2 Site Specific QAPP The majority of sampling activities performed by MDEP/RCRA will not require the development of a site specific QAPP. However, for those projects requiring the strictest QA/QC guidelines, a site specific QAPP will be generated. A QAPP may be generated for a specific site if the MDEP/RCRA project manager and supervisor, and the appropriate Technical Services personnel determine one is necessary. An example in which a site specific QAPP may be generated would be a Site where there is a high probability of litigation. If a QAPP is necessary, it will include the elements listed in SOP DR#016 - Development of a Site Specific QAPP found in Appendix B. Page 10 of 19 QAPPs originating at MDEP will be reviewed for the elements described in SOP DR#016 and a page carrying the approval signature of the MDEP project manager, project QA reviewer [project hydrogeologist, engineer, or chemist] and date, will be kept with the project file. QAPPs developed by outside contractors shall be reviewed and approved by the MDEP project manager, signed and filed as above. All active QAPPs shall be reviewed periodically as necessary by the responsible project manager, and documentation of this review, including any changes to the work plan, shall be filed as above. Any QAPP review (e.g., for technical validation) by a person other than the MDEP project manager shall likewise be documented. 6.3 Implementation of SAP and Generation of a Sampling Event Trip Report It is expected that field samplers and analytical laboratories will follow standard operating procedures and adhere to generally accepted good field and laboratory practices. Appendix B contains standard operating procedures (SOP) for the MDEP RCRA Program. With that stated, the sampling event trip report [SETR] will provide documentation of the actual sampling event. Requirements for generation of a SETR can be found in SOP DR#013 Documentation of Field Notes and Development of a SETR found in Appendix B. Generally, the SETR will describe actual sampling locations, field conditions, sample container numbers, deviations from the SAP and SOPs, copies of chains of custody, and any information that the field personnel deem relevant to the field activities for that sampling event. The person responsible for developing the SETR will be stated in the SAP for that activity. Occasionally certain quality assurance requirements cannot be met, and deviations from SAPs and SOPs are needed to overcome real life conditions. In such cases, the reason for the deviation should be stated in the SAP or the SETR along with the expected or observed impact on the data. 7.0 EQUIPMENT & SUPPLIES 7.1 Equipment A variety of equipment is available to MDEP/RCRA for conducting soil and groundwater investigations. This includes equipment that is owned by MDEP/RCRA directly, and equipment that is owned by MDEP/TS and is available through interdepartmental loan. A list of the available equipment and SOP for operating this equipment can be seen in Appendix B. With this equipment available to MDEP/RCRA and the available personnel expertise, substantial investigations into hazardous substance contamination can be conducted. All equipment shall be maintained and calibrated according to the manufacturer's instructions and in accordance with the appropriate analytical Page 11 of 19 methods. Manufacturers instructions and other instructional documentation will be kept with the field staff of the MDEP/RCRA, if MDEP/RCRA owned, or with designated Technical Services staff, if owned by MDEP/TS. As new equipment is purchased or other otherwise made available to MDEP/RCRA, the equipment list and SOPs will be updated, as needed. All equipment and supplies are inspected and accepted when received. Equipment that requires calibration for use, such as PIDs, ph meters, etc., shall be calibrated routinely on a monthly basis, or as directed by the manufacturer, and prior to its use in the field at the beginning of each working day. Additional calibration may also be conducted throughout the work day as directed by the manufacturer, or as deemed necessary by the field personnel when equipment appears to be reporting suspect results. Documentation of routine calibration and maintenance shall be kept in the equipment calibration and maintenance logbook, which is kept with the equipment at the storage warehouse. Documentation of equipment calibration prior to and during its use in the field will be noted in the field logbook of the person conducting the calibration Supplies Supplies needed to perform sampling under this program are ordered and managed by the Geology Technician or support staff in MDEP/TS, and stored in a clean secure room. Stocks are continually checked to ensure that an adequate supply is maintained. Organic free water used for trip blanks and field blanks is either purchased or supplied from home drinking water wells by MDEP staff. All water is tested for VOC content prior to use. Sample bottles, preservatives, and chain of custody forms are supplied by the Maine Health and Environmental Testing Laboratory (HETL) and other laboratories certified for appropriate analyses. 8.0
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